--- title: "CASP Transitional Period: Country-by-Country Expiry Calendar (2026)" slug: casp-transitional-period-calendar publishedAt: 2026-04-27T09:00:00Z author: Finconduit Editorial Team tags: MiCA, AMLR, TFR canonicalUrl: https://finconduit.com/resources/casp-transitional-period-calendar --- # CASP Transitional Period: Country-by-Country Expiry Calendar (2026) Country-by-country CASP transitional period expiry calendar for the EEA — when each member state's grandfathering window closes and what conversion programme each operator must run. **MiCA** became fully applicable on **30 December 2024**, and with it the deadline that every legacy crypto operator in the EEA must plan around: the day the **transitional period** in their home member state **expires**. [Markets in Crypto\-Assets Regulation](https://eur-lex.europa.eu/eli/reg/2023/1114/oj) **Article 143** lets each member state grant existing **CASP**\-perimeter operators \(registered **VASP**s, pre\-**MiCA** national\-licence holders\) a grace period of up to **18 months** — but the choice is national, the wording is divergent, and the **expiry** dates differ from country to country.¹[^1] Get this calendar wrong and you discover, three months too late, that your **VASP registration** in **Hungary** expired in January 2026 while your customers thought you were still authorised. Get it right and you have a precise drop\-dead date for the conversion programme: when the application file must lodge, when local\-director hires must close, when the safeguarding accounts must open. This guide tabulates the **transitional period** chosen by each EEA member state, identifies the **shortest** and **longest** **grandfathering window**s, and lays out the 9–18 month conversion programme that needs to land before whichever date applies to you. The calendar is verified against published NCA notices to the extent NCAs have published; member states still finalising their transposition are flagged as 'pending — verify directly'. ## How the Transitional Regime Works [MiCA Article 143](https://eur-lex.europa.eu/eli/reg/2023/1114/oj)\(3\) is the legal basis. It allows a member state to permit operators already providing crypto\-asset services under that member state's pre\-**MiCA** national regime to continue operating without a **CASP authorisation** for up to **18 months** from **30 December 2024** — i.e., until **1 July 2026** at the latest. Member states may opt for a shorter window, no **transitional period** at all, or a more bespoke runway tied to specific licence types.²[^2] The **transitional period** is not a licence. It is a non\-enforcement window: the NCA does not pursue authorisation breaches against existing operators during the period, but the operator is otherwise expected to comply with the substantive **MiCA** rulebook \(governance, **AML**, Travel Rule, prudential capital\). At the end of the period, the operator either holds a granted **CASP authorisation** or stops providing services to EEA residents. > **Warning:** The transitional period applies only to operators that were authorised, registered, or otherwise permitted to provide crypto\-asset services in their home member state before 30 December 2024. New entrants do not benefit from any grandfathering — they must apply for full CASP authorisation from day one. Buying a registered shell entity to acquire transitional status is closely scrutinised by NCAs and frequently rejected on substance grounds. ## The Country\-by\-Country Expiry Calendar The table below summarises each EEA member state's **transitional period** as published or confirmed by the NCA. Where the NCA has published official guidance, the date is shown explicitly; where the member state has opted for the maximum 18\-month window without further specifying, the **expiry** is **1 July 2026**; where transposition is still pending, the row is marked 'verify with NCA'. *Table: MiCA transitional period expiry by EEA member state \(2026\). Verify directly with the home NCA before submitting an authorisation file.* | Member state | NCA | Transitional period chosen | Expiry date | | --- | --- | --- | --- | | Germany | BaFin | Reduced — \~12 months from full applicability | 30 December 2025 | | Netherlands | AFM / DNB | Reduced — short, transposition\-driven | 30 June 2025 \(AFM guidance\) | | Hungary | MNB | Reduced — early termination | 1 January 2026 \(verify\) | | Denmark | Finanstilsynet | Reduced | 30 June 2025 \(verify\) | | Estonia | FIU | Reduced — VASP\-specific transition | Varies by VASP licence vintage | | Lithuania | Bank of Lithuania | Full 18 months | 1 July 2026 | | Cyprus | CySEC | Full 18 months | 1 July 2026 | | Ireland | Central Bank of Ireland | Full 12 months \(CBI guidance\) | 30 December 2025 | | Malta | MFSA | Full 18 months — VFA Act conversion | 1 July 2026 | | France | AMF / ACPR | Full 18 months | 1 July 2026 | | Spain | CNMV | Full 18 months | 1 July 2026 | | Italy | Consob / Banca d'Italia | Full 18 months | 1 July 2026 | | Portugal | Banco de Portugal | Full 18 months | 1 July 2026 | | Belgium | FSMA | Full 18 months | 1 July 2026 | | Luxembourg | CSSF | Full 18 months | 1 July 2026 | | Austria | FMA | Full 18 months | 1 July 2026 | | Czech Republic | ČNB | Full 18 months | 1 July 2026 | | Slovakia | NBS | Full 18 months | 1 July 2026 | | Slovenia | ATVP / BoS | Full 18 months | 1 July 2026 | | Greece | HCMC | Full 18 months | 1 July 2026 | | Croatia | HANFA | Full 18 months | 1 July 2026 | | Bulgaria | FSC | Full 18 months | 1 July 2026 | | Romania | ASF | Full 18 months | 1 July 2026 | | Latvia | Bank of Latvia | Full 18 months | 1 July 2026 | | Poland | KNF | Pending transposition — verify | TBD \(likely 1 July 2026\) | | Finland | FIN\-FSA | Full 18 months | 1 July 2026 | | Sweden | Finansinspektionen | Full 18 months | 1 July 2026 | | Norway \(EEA\) | Finanstilsynet | EEA implementation pending | TBD — verify | | Iceland \(EEA\) | FME | EEA implementation pending | TBD — verify | | Liechtenstein \(EEA\) | FMA | Full 18 months | 1 July 2026 | > **Note:** The shortest expiries are Germany \(30 December 2025\), Ireland \(30 December 2025\), Netherlands \(30 June 2025\), and Denmark \(30 June 2025\). Operators registered in those member states must compress the conversion programme accordingly. The longest expiries cluster on 1 July 2026 — most member states opted for the full 18\-month window. ## What 'Expiry' Actually Means On the Day The day after the **transitional period** **expires**, three things become true. First, the legacy national **VASP**/wallet\-provider registration ceases to authorise the provision of crypto\-asset services. Second, the operator must hold a granted **MiCA CASP** authorisation, an **in\-principle approval** that the NCA has explicitly converted into operational permission, or it must stop providing services to EEA residents. Third, services provided to EEA residents without a valid authorisation become a regulatory breach immediately enforceable by the NCA. Several NCAs \(**Bank of Lithuania**, **Central Bank of Ireland**, **BaFin**\) have published guidance that operators with a complete **CASP** application file lodged before the transitional **expiry** — and pending decision — may continue operating beyond the formal **expiry** until the NCA decides. Other member states \(**Cyprus**, **Malta**\) have signalled the same approach informally but have not published the same in writing. Plan to lodge a complete application 6–9 months before **expiry**, not the day before. ## The 12\-Month Conversion Programme Conversion from a legacy **VASP registration** to a granted **CASP authorisation** is not paperwork — it is a programme spanning regulatory, legal, technology, and HR workstreams. The minimum runway is 9–**12 months** for a member state with a 12\-month **transitional period** \(**Germany**, **Ireland**\), 12–**18 months** for the **1 July 2026** cluster. *Table: Conversion programme — workstreams and minimum runway from project start to operational launch under the new licence.* | Workstream | Minimum duration | Outputs | | --- | --- | --- | | 1. Gap analysis vs MiCA \+ AMLR | 4–8 weeks | Programme of Operations, gap register, remediation plan | | 2. Governance build\-out — local directors, MLRO, fit\-and\-proper | 8–16 weeks | Two EEA\-resident executive directors hired and onboarded; MLRO regulator\-approved | | 3. AML programme rewrite — risk assessment, CDD, EDD, sanctions, Travel Rule | 10–14 weeks | 30–80 page AML programme, Travel Rule provider contract signed, Transfer of Funds Regulation workflows live | | 4. ICT / DORA — incident reporting, third\-party register, exit plans | 8–12 weeks | DORA\-aligned ICT framework documented and tested | | 5. Capital — own funds segregated, safeguarding accounts opened | 6–10 weeks | Class 1/2/3 capital deposited; safeguarding bank relationship live | | 6. Application file submission | End of month 6 at latest | Complete authorisation file lodged with NCA | | 7. NCA review iterations | 4–8 months | Authorisation granted \(or granted with conditions\) | | 8. Operational cutover under new licence | 30–60 days post\-grant | Customer\-facing services migrated; legacy registration retired | ## Common Conversion Pitfalls - Treating conversion as paperwork. **CASP authorisation** requires substance — local directors, capital actually segregated, contracts with named Travel Rule and analytics vendors. Legacy **VASP** files do not satisfy this. - Submitting close to the **expiry**. NCAs will not prioritise late\-arriving files, and operating beyond **expiry** without a complete pending application is enforcement risk. - Migrating to a member state with a longer window without considering substance requirements. The **Bank of Lithuania** has rejected applications where the entity moved from a shorter\-window jurisdiction without genuine local operations. - Assuming the legacy **passport** survives. National **VASP registration**s did not provide **EEA passport**ing — only the granted **CASP authorisation** does. - Forgetting [AMLR](https://eur-lex.europa.eu/eli/reg/2024/1624/oj). The **AML** Regulation overlays a single EU **AML** rulebook from 10 July 2027 — your **AML** programme must be drafted to [AMLR](https://eur-lex.europa.eu/eli/reg/2024/1624/oj) standards, not just current [EBA Guidelines](https://www.eba.europa.eu/).⁵[^3]⁶[^4] ## Frequently Asked Questions ### What happens if I miss the transitional **expiry** without an authorisation in hand? Two possibilities. If your **CASP** application is complete and lodged with the NCA before the **expiry**, most NCAs \(**Bank of Lithuania**, **Central Bank of Ireland**, **BaFin** published guidance\) allow continued operation pending the decision. If no application is lodged, services to EEA residents on the day after **expiry** are a regulatory breach and trigger immediate cease\-and\-desist powers. Several member states have indicated they will publish public lists of operators whose **transitional period** has ended without authorisation — a serious correspondent\-banking and reputational risk. ### Can I move my entity to a longer\-window member state to buy time? Technically possible, practically very hard. A simple corporate redomiciliation does not transfer the legacy authorisation under **MiCA Article 143** — the new home member state only recognises the **transitional regime** for entities that were registered there before **30 December 2024**. You would be applying as a new entrant. The **Bank of Lithuania** has explicitly rejected applications that attempted this without genuine local operations and substance. ### Does the **transitional period** cover all crypto\-asset services? Only those services already authorised or permitted under the legacy national regime. If your pre\-**MiCA** permission covered exchange and custody but not portfolio management, the **transitional period** does not cover the new service — you need a fresh **CASP authorisation** for portfolio management before launching it. Several NCAs have flagged this as a frequent compliance gap during early\-2026 reviews. ### What about the Travel Rule during the **transitional period**? The [Transfer of Funds Regulation](https://eur-lex.europa.eu/eli/reg/2023/1113/oj) applies from **30 December 2024** with no transitional carve\-out. Even an operator inside the **CASP** **transitional period** must run a fully compliant Travel Rule capability — the €1,000 data\-set rules, self\-hosted wallet workflow, and 24\-hour aggregation apply from day one. Failure here is a **TFR** breach independent of **MiCA**.⁷[^5] ### If my member state has not yet published guidance, what should I assume? Default to the maximum 18\-month window expiring **1 July 2026** — but treat the assumption as provisional and verify with the NCA in writing. Several member states \(**Poland**, **Norway**, **Iceland**\) had not finalised guidance as of late 2025. Their dates should crystallise during 2026; build your conversion programme to the conservative end of the range. ### How does this interact with the **AMLR** and **AMLA** rollout in 2027? **AMLR** replaces the patchwork of national **AML** regimes with a single EU rulebook from 10 July 2027 — and **AMLA** begins direct supervision of \~40 highest\-risk obliged entities from 2028. A **CASP** that converts in 2026 must build its **AML** programme to **AMLR** standards, not the legacy 5**AML**D national variants — otherwise you remediate the same programme twice within **18 months**. > **Call to action:** Need a conversion roadmap mapped to your member state's expiry date? Finconduit builds CASP transition programmes — gap analysis, governance, AML programme, application file — for legacy VASPs converting before the deadline. Get a free conversion\-fit assessment. ## Related Guides - [MiCA Compliance Guide for CASPs](/resources/mica-compliance-guide-casps): Authorisation walkthrough — capital, governance, supplier stack - [EEA vs UK vs Offshore: Where to Incorporate Your Crypto Business](/resources/eea-uk-offshore-crypto-incorporation): Which jurisdiction maximises regulatory access and tax efficiency - [AML Compliance for Crypto Firms](/resources/aml-compliance-crypto-6amld): What the 6**AML**D requires from **CASP**s and **VASP**s - [MiCA Travel Rule Providers Compared](/resources/mica-travel-rule-providers-compared): Notabene vs Sumsub vs Sygna vs Veriscope The **transitional period** was designed to give legacy operators time. It was not designed to give them indefinite leniency. The **CASP**s that survive the conversion are the ones that started the programme **12 months** before their **expiry**, hired the local executives **6 months** before submission, and lodged a complete file 6–9 months before the deadline. The **CASP**s that don't survive are the ones that learned in February 2026 that their member state opted for a shorter window than they assumed. - [MiCA Reverse Solicitation: When Can Offshore Firms Serve EU Clients?](/resources/mica-reverse-solicitation-offshore) — the fallback for firms whose CASP authorisation slips past the transitional window. - [The Reverse Solicitation Evidence Pack](/resources/reverse-solicitation-evidence-pack-crypto) — the seven\-document file every offshore firm needs if it intends to invoke the defence during the transition. - [The MiCA Crypto\-Asset White Paper](/resources/mica-white-paper-requirements) — the disclosure document and notification obligations that apply once the transitional period ends. ## Footnotes [^1]: Regulation \(EU\) 2023/1114 \(MiCA\), OJ L 150, 9.6.2023. [^2]: MiCA Article 143 — Transitional measures. Allows member states to grant existing CASP\-perimeter operators a transitional period of up to 18 months from 30 December 2024. [^3]: EBA Guidelines on the management of money laundering and terrorist financing risks \(EBA/GL/2021/02\). [^4]: Regulation \(EU\) 2024/1624 \(AML Regulation — AMLR\), applicable from 10 July 2027. [^5]: Regulation \(EU\) 2023/1113 \(Transfer of Funds Regulation\), applicable from 30 December 2024. --- Source: https://finconduit.com/resources/casp-transitional-period-calendar